120 MENSHEALTH.COM June 2014Prop styling.docx

120 MENSHEALTH.COM | June 2014
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YOU PLAY, YOU PAY
Small-screen violence may still have a big effect on your brain.
Smartphones are great because they let grown men geek out
playing shooter
games without looking like, well, geeks. The problem? Tapping
and zapping
on your morning train ride may make you more aggressive and
less empathetic
at work, says Bruce Bartholow, Ph.D., a professor of
psychology at the University
of Missouri. In fact, the easy accessibility of these games may
cause them to be
more problematic than their big-screen brethren. “If you have
the game in your

pocket and can play all the time, there may be no opportunity
for those effects to
diminish,” says Bartholow. His advice: Limit yourself to an
hour a day. —LILA BATTIS
BY
TOM McGRATH
PHOTOGRAPHS BY
CRAIG CUTLERSpecial
Report
WHEN KILLING
IS A GAME
As shoot-’em-up video gaming becomes even
more immersive, scientists are racing to finally
answer a controversial question: Does virtual
violence turn some boys into real killers?
NONE OF THIS IS REAL.
Still, as I enter the building through the open
doorway, my body tenses and my eyes scan the
room as quickly as possible. Is there danger in
here? I move forward tentatively, my senses
heightened in anticipation. Suddenly I see a fig-
ure in the shadows. My finger moves instantly,
twitching for what seems like dozens of times as
the rat-a-tat-tat explodes around my ears. I see
a body slump. It’s the one I’ve been aiming at,
and I feel a surge of satisfaction in my chest.
It’s a Saturday afternoon, and though physi-

cally I’m perched on a chair in my basement
with a smooth plastic Wii controller in my hand
and a chunky 15-year-old TV on the table in
front of me, mentally I’m in the war-torn streets
of whatever unidentified city is the setting for
Call of Duty: Modern Warfare 3. I’ve been play-
ing the game for the last 45 minutes, and though
my skill level is pretty lame—I seem to be killed
almost as often as I kill—in many ways I feel
lost in this other world.
I play for about 10 more minutes, blow-
ing away a few more bad guys, until I’m blown
away myself (again) and decide I’ve had enough.
Because I’m in my basement and not in a lab
somewhere hardwired to all sorts of monitors,
it’s difficult to say for sure what’s happening to
me physiologically. But it’s a safe bet that my
heart rate and blood pressure are both elevated
and stress hormones are coursing through my
body. I feel a little on edge.
Which, as I walk up the stairs to the kitchen,
makes me wonder: Would you really want to be
my wife, my kids—even my dog—right now?
FOR THE PAST TWO DECADES, THE WORLD HAS
been engaged in a massive and unprecedented
social experiment: What happens when mil-
lions of people—most of them boys and young
men—are allowed to pretend, in the most vivid
way possible and often for hours on end, that
they’re professional killers? Does the experience
increase the odds that they’ll someday turn into
killers themselves? Does it shape their person-
alities in other ways? Or is it all simply forgotten

in the hours after the game ends?
The anecdotal evidence isn’t reassuring, at
least in light of the mass shootings of recent
years and the number of those shooters who’ve
had strong connections to violent video games.
Columbine’s Eric Harris and Dylan Klebold, for
example, were serious fans of the sci-fi horror
game Doom. James Holmes, who opened fire in
a movie theater in Aurora, Colorado, killing 12
people and injuring 58 others, allegedly told one
person that during the shooting he felt like he
was “in a video game.” And late last year it was
revealed, in Matthew Lysiak’s book Newtown:
An American Tragedy, that Adam Lanza, the
20-year-old behind the Sandy Hook Elementary
tragedy, had logged more than 500 hours play-
ing the first-person shooter game Combat Arms,
during which he recorded a staggering 83,496
kills (including nearly 23,000 head shots).
And yet scientific evidence about the effects of
violent video games is muddled. On one side is a
group of researchers, backed by dozens of stud-
ies, who are convinced that our mass infatuation
with such titles as World of Warcraft and Grand
Theft Auto is a public health threat and that such
games are making us more aggressive and less
sensitive to violence. What’s more, these experts
claim, the threat is particularly strong for men:
Men buy the majority of games, and according
to a Harris Interactive survey, young men are
about 2½ times as likely as young women are to
describe themselves as “addicted” to playing.

“We can’t say whether the games lead to vio-
lent criminal behavior. But we know they lead
to aggressive behavior and thinking,” says Brad
J. Bushman, Ph.D., a professor of communication
and psychology at Ohio State University who
has spent the past 25 years looking at the effects
of violence in media. Bushman coauthored per-
haps the most persuasive paper on the topic, a
2010 meta-analysis that looked at more than 100
previous studies. The paper’s conclusion: Play-
ing violent video games ranks alongside sub-
stance use, poverty, and abusive parents as a risk
factor for both short-term aggression and the
development of aggression-prone individuals.
On the opposite side of the argument is
another contingent of researchers who essen-
tially believe that all of the above is b.s. They
counter that much of the research indicting
video games is flawed and that their own stud-
ies generally show no ill effects from playing.
Indeed, they see the hand-wringing as classic
“moral panic”—people fearing and demoniz-
ing something because they don’t understand
it. “Obviously video games have an effect on us
or we wouldn’t play them,” says Christopher
122 MENSHEALTH.COM | June 2014
When Killing Is a GameSpecial Report /
HOW TO PROTECT

A TRIGGER-HAPPY KID
Ban a boy from playing violent video
games, and you may start a war. Instead,
achieve détente by using these strate-
gies from human behavior researcher
Cheryl Olson, Sc.D., and clinical psycholo-
gist Catherine Steiner-Adair, Ed.D.
Ferguson, Ph.D., a professor of clinical psychology
at Stetson University and an outspoken oppo-
nent of the video game critics. “But do they have
any dramatic public health effect? No.”
The stakes are huge. The video game industry,
which in 2013 made about $93 billion worldwide,
has surpassed the global film industry. Given that
four of the five best-selling games of last year
were violent shooter titles, software develop-
ers and even game-system manufacturers may
take a hit if violent games are found guilty. More
important, the popularity of these games may
mean that not only are more Adam Lanzas out
there but new ones are being trained every year.
WHEN HE STARTED PLAYING COMBAT ARMS IN
2009, Lanza was a skinny, socially awkward
17-year-old who’d been diagnosed with Asperg-
er’s syndrome, a form of autism disorder. Or at
least that’s who he was in real life. In the game,
onscreen, he was able to create a different ver-
sion of himself: a muscle-bound soldier wearing
fatigues, goggles, and a black beret and carrying a
military assault rifle. In Lanza’s chosen mission
in Combat Arms, players were to rack up a certain
number of kills as quickly as possible—even if it
meant turning the rifle on themselves and com-

mitting suicide—and Lanza became obsessed
with it. By 2011, he had moved on from Combat
Arms to other violent games, such as Call of Duty
and Call of Duty: Modern Warfare 2, where again
the goal was to tally as many kills as possible.
Had Lanza been born just a generation ear-
lier, such a violent outlet would have been hard
to come by even in the world of video games. In
the early days, of course, Pac-Man and Donkey
Kong dominated, and in retrospect these games
seem not just benign but almost sweet. That
began to change in the 1990s with the develop-
ment of a new genre: the first-person shooter.
Titles like Wolfenstein 3D, Doom, and several
others allowed players to see the world not from
an objective outside perspective but from the
point of view of the person doing the shooting.
As the technology and graphics improved dra-
matically in the following decade, first-person
shooters exploded in popularity.
“In a lot of ways, it’s the easiest thing to do,”
says game writer and designer Walt Williams
when asked why violence is at the heart of so
many games. Almost all video games operate on
the same principle: giving players obstacles to
overcome, pixels that need to be clicked on and
made to go away. Creating those obstacles in the
form of people—and making them disappear
with virtual bullets—is one of the simplest solu-
tions game creators have.
But Williams believes that the attraction
of first-person shooter games runs deeper. “I
think it’s connected to a power fantasy,” he says.

“You’re put in a situation that reinforces the
power being in your hands. That’s appealing.”
So how does your body react when that power
takes the form of shooting an onscreen repre-
sentation of a human being who might shoot you
first if you don’t act quickly enough? Numerous
studies have shown an uptick in all the measures
you might imagine: blood pressure, heart rate,
stress hormone levels. In short, though the vio-
lence isn’t real, your body reacts as if it were.
Even more intriguing is what happens in
your brain. In a 2011 study from Germany,
researchers showed violent screen shots from
the game Counter-Strike to gamers with first-
person-shooter experience. Typically, showing
people negative images provokes activity in the
lateral prefrontal cortex, the area involved in
emotional processing and control. In this study,
though, the experienced gamers showed sig-
nificantly less activity in that region. They had
become desensitized to the death and gore.
OF COURSE, PHYSIOLOGY IS ONE THING; BUT
behavior is another. A number of studies from
the 1990s and early 2000s showed that playing
violent video games leads, at least in the short
term, to more-aggressive attitudes, emotions,
and actions. In one of the most frequently cited
studies—published in the Journal of Personal-
ity and Social Psychology in 2000—college-age
students played either the violent game Wolfen-
stein 3D or the nonviolent Myst. Afterward they
answered a questionnaire designed to measure

their attitudes and emotions; then they took
part in a competitive activity in which they could
blast another student with white noise. Those
who’d played Wolfenstein 3D not only demon-
strated thoughts that were more aggressive but
also delivered longer noise blasts to their oppo-
June 2014 | MENSHEALTH.COM 123
Il
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Q
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O

N
E
Y
Do you handle
the obstacles
you face in real
life the same way
you handle those
on the screen—
with aggression?
Both events made Ferguson, now 42, leery
of grownups overreacting to things they don’t
understand. “Adults clearly didn’t know what
they were talking about,” he says. Still, his skep-
ticism didn’t fully kick in until he became an
adult himself and read a research paper stating
that the link between violent media and aggres-
sive behavior was nearly as strong as the link
between smoking and lung cancer. Ferguson’s
reaction: That’s absurd.
Much of Ferguson’s career since then has
been spent trying to debunk the notion that a
strong scientific connection exists between vio-
lent media—particularly violent video games—
and negative outcomes of any kind.
For starters, he questions the methodology of
many of the studies, arguing that they frequently
lack standardization, often don’t control for gen-
der differences, and don’t necessarily measure
what they purport to measure. One of his favor-
ite examples is a 2004 study supposedly prov-

ing that playing violent video games gave college
students a more aggressive mindset. His gripe?
The researchers’ chosen method for measuring
attitudes was asking study participants to fill in
the missing letter in the following word: explo_e.
As it happened, the participants who had played
violent games were more likely to put a d in that
word (“explode”) than the control group, who
more often chose r to spell “explore.” But, Fer-
guson wonders, does that really tell us that they
were likely to be aggressive?
He also suspects publication bias—that is,
some journals choose to publish studies that
show a result over those that show nil effects.
Finally, he’s conducted several of his own studies
over the years and says they all fail to prove a
significant negative effect from playing games.
In one of Ferguson’s most recent studies,
published in January 2014, he and his coau-
thors explored the question many have asked
over the years: Are violent games particularly
dangerous for people with preexisting mental
health conditions—specifically children diag-
nosed with either depression or ADHD? The
study, which appeared in the Journal of Youth
and Adolescence, found no
PUT UP NEW TARGETS
Pinpoint the game elements that
bother you and the features he’s look-
ing for, and then try to find a compro-
mise, says Olson. If he loves combat
and competition, nudge him toward
fantasy or sci-fi games in which he

can annihilate aliens and not people.
SAY, “SHOOT HOOPS, NOT PEOPLE”
Children use gaming to de-stress after
school, but killing stuff is a bad coping
tool. So set aside the first hour at
home for any sport or game except
the video kind. “If video games aren’t
an option, he’ll learn to deal with stress
in a better way,” says Steiner-Adair.
TELL HIM TO STAND DOWN
Abbreviating his gaming sessions may
lead to frustration—players often can’t
advance far in brief periods. Instead,
designate game-free days, says
Steiner-Adair. In return, promise a few
long stretches of game time so he has
a chance to advance to a new level.
RECRUIT HIS BUDDIES
Those immersive shoot-’em-ups can
encourage isolation. To counteract
that, find games that foster children’s
capacity to play together, says Steiner-
Adair. Go to commonsensemedia.org,
search for games based on skills
taught, and try to agree on a few. —L.B.
nents than the Myst players did. The virtual
violence, in other words, seemed to prime them
to react more aggressively in the real world.
More-recent research suggests that the pro-
pensity toward aggression isn’t something that
necessarily fades minutes after the game has

ended. A 2008 study published in Pediatrics
measured the aggressiveness of Japanese and
American schoolkids at two different times,
with three- to six-month gaps between assess-
ments. Those who habitually played violent
video games were more likely to be aggressive
during the first measurement period, and their
aggression was also more likely to increase by
the second one. Another study, published in
Developmental Psychology in 2012, surveyed
high schoolers annually from ninth to 12th grade
about their video game habits and aggressive
behavior. Higher amounts of violent video game
play predicted higher levels of aggression.
It should be noted that none of these stud-
ies link video games to violent behavior. That’s
important because there’s a difference between
aggression and violence: Aggression is defined
as any behavior carried out with the intent to
harm another person, while violence is an act
intended to cause extreme physical harm, such
as injury or death. Still, researchers say, we need
to be concerned. “I’m much more interested in
types of aggression we experience in our every-
day lives,” says Doug Gentile, Ph.D., a professor of
psychology at Iowa State University. He means
the general way we interact with one another: If
someone bumps into you, do you see it as an acci-
dent or a provocation? Does your temper flare
more easily than it normally would? Put another
way, do you handle the obstacles you face in real
life the same way you handle those you face on
the screen—with aggression? The research so far
suggests that for heavy gamers, the answer is yes.

Studies also suggest that video games, which
make you an active participant in the onscreen
proceedings, are more powerful than passive
media, like movies or TV. In a 2008 study, Euro-
pean researchers had kids ages 10 to 13 do one of
three things—play a violent video game, watch
someone else play the same game, or play a non-
violent game. Afterward, boys who had played
the violent game were the most aggressive of the
three groups. (Curiously, girls showed no dif-
ference in aggression among the three groups—
a fact that the researchers speculate could be
because boys in the study had played a lot of
violent video games outside the study, while the
girls had played relatively few. The boys, in other
words, may have been hardwired by previous
game exposure to behave aggressively.)
For Gentile, none of these effects are surpris-
ing. To habitually engage in violence in the
virtual world, he believes, is to train your brain
to think in a certain way, which then manifests
in aggressive behavior in life.
“Your grandmother was a great neurosci-
entist,” Gentile says. “She always told you that
practice makes perfect.”
ONCE UPON A TIME, PSYCHOLOGY PROFESSOR
Chris Ferguson was an awkward teenager too.
Or at least he was a fan of Dungeons & Dragons, a
role-playing game that in the 1980s was a target
of some conservative Christians who feared that
its fans were on a slippery slope toward devil
worship. (Others feared that it put kids on a less

alarming path toward Renaissance fairs.) This
was the era during which Tipper Gore mounted
her famous crusade against overly explicit song
lyrics; as a result, the music industry was forced
to put parental warning stickers on certain
albums lest teenage souls be corrupted. CONTINUED ON
PAGE 171
“In real life,
killing is
a traumatic
experience.
But in video
games, it can
happen a
hundred times
a minute.”
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WHEN KILLING IS A GAME, CONT. FROM P. 123
evidence of increased bullying or delin-
quent behaviors among kids in the trial
who played violent video games.

To Ferguson, the lack of impact was
to be expected. In contrast to Doug Gen-
tile and other researchers who believe
that video games condition our brains
to respond to perceived threats in cer-
tain ways, Ferguson says our gray matter
is quite capable of responding to fantasy
scenarios and real threats differently.
“People aren’t stupid,” he says bluntly. As
evidence, he notes that even though video
games have soared in popularity in the
past 13 years, the youth violent crime rate
reached a 32-year low in 2012.
What about those mass shooters who
were so devoted to their video games?
Not only is blaming video games the 21st-
century equivalent of people freaking out
over the dangers of Dungeons & Drag-
ons, Ferguson argues, but it also distracts
us from what he believes is the actual
issue underlying all those shooting cases:
untreated mental illness.
SO WHO’S RIGHT? OR PERHAPS MORE
important, where do we go from here?
After the Newtown shootings, President
Obama asked Congress to fund deeper
research into the effects of violent video
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WHERE TO BUY
“No-Sweat Summer Looks,” page 86
WHERE TO BUY
“Swim Trunks: The Rules,” page 66
games, which hopefully could help clarify
our understanding. In the meantime, one
intriguing path comes from within the
game industry itself.
Over the past few years, game creator
Walt Williams has found himself becom-
ing concerned not so much with the lev-
els of violence in video games as with the
banality of it—that is, how mundane it all
seems to the player.

“In real life, killing is a traumatic expe-
rience,” Williams says. “But in video
games, it’s something that can happen a
hundred times a minute.”
In 2012, a new game debuted that
Williams helped write and design. It was
called Spec Ops: The Line, and the goal
was to portray violence—and its effects—
in a much more realistic way. At one
point, for example, the game’s main char-
acter, a soldier named Walker, is faced
with the possibility of having to open fire
on a group of civilians, albeit hostile ones,
in order to survive. As the action pro-
gresses, Walker (that is, you, the game
player) encounters as many moral chal-
lenges as physical ones. Williams says one
of the ideas driving the entire game was
this: “What if the toll of taking a life actu-
ally weighed on you?”
For what it’s worth, Spec Ops: The Line
received some positive critical notices,
but it was certainly no Grand Theft Auto in
terms of sales. Given the choice between
moral ambiguity and a power fantasy, per-
haps the market has spoken. �
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AGE0177
Nov-18th-2015
Research Introduction
Violent video games is a topic that has some bad
consequences. These bad consequences are actually harmful to
children. Violent video games effects children negatively and
when it effects them it leads them to do or experience bad
actions. Such as, leading the children to aggression, bullying
their peers in schools, leading them to crimes, and experiencing
moral changes in their behavior. Parents and the government are
the responsible people for this issue. Parents have the ability to
control their children and the government has the power to
prevent these kinds of games. This paper is research that will
give an explanation of violent video games first. It will
basically argue on parents and the government because they are
responsible people for violent video games issue. It will also
answer the question of how violent video games effect children
and what these kinds of games lead to.
Supreme Court Debates, a Pro & Con® Monthly | December
2010 (Vol. 13, No. 9)
Violent Video Games
Is the California Ban on the Sale of Violent Video Games to
Minors
Constitutional?
PROS
Arnold Schwarzenegger and Edmund G. Brown Jr., et al.
Petitioners
Zackery P. Morazzini, Counsel of Record

On October 7, 2005, the State of California enacted Civil
Code sections 1746-1746.5, which prohibited the sale or
rental of “violent video games” — defined as ones that depict
“killing, maiming, dismembering, or sexually assaulting an
image of a human being” — to minors under the age of 18.
Businesses that violate the Act can be fined up to $1,000 per
violation. In support of passage, State legislators cited studies
by social scientists and medical
associations that they argued established a correlation between
playing violent video games and
an increase in aggressive thoughts and behavior, antisocial
behavior, and desensitization to
violence in both minors and adults. Shortly after passage, the
Entertainment Merchants
Association and Entertainment Software Association —
representing the video game and
software industries — filed a suit against California Governor
Arnold Schwarzenegger, Attorney
General Edmond G. Brown, Jr., and three San Jose-area
officials to block implementation of the
Act, claiming that it violated the First Amendment protection of
free speech. After the U.S.
District Court for the Northern District of California ruled in
favor of the software companies,
the State appealed. On February 20, 2009, the Ninth Circuit
U.S. Court of Appeals affirmed the
lower court decision. The State then appealed to the U.S.
Supreme Court, which granted
certiorari on April 26, 2010. Zackery P. Morazzini is
supervising deputy attorney general for the
State of California. The following is excerpted from the Brief
for the Petitioners as submitted to
the U.S. Supreme Court on July 12, 2010.
California’s prohibition on the sale of offensively violent video

games to minors is
constitutional. Whatever First Amendment value these games
may possess for adults, such
games are simply not worthy of constitutional protection when
sold to minors without parental
participation. There is no sound basis in logic or policy for
treating offensively violent, harmful
material with no redeeming value for children any different than
sexually explicit material.
I. The First Amendment Permits States to Restrict the Sale of
Offensively Violent Video
Games to Minors.
As this Court unequivocally held in Ginsberg v. New York
(1968), States may properly restrict
minors’ access to material that is fully protected as to adults.
This ruling, and the reasoning
supporting it, is equally applicable to regulations on minors’
access to offensively violent
material. Such material, like obscenity, is harmful to minors and
has little or no redeeming social
value for them. Parents are entitled to support of the law in
their efforts to protect minors from
this material in order to direct their ethical and moral
development. Because the State is only
limiting this material with respect to its sale to minors, strict
scrutiny does not apply to the
© 2010 Congressional Digest Corp. |
www.congressionaldigestdebates.com | Page 15
2010 (Vol. 13, No. 9)

Violent Video Games
California act. Rather, history, tradition, and our continuing
understanding of the inherent
vulnerability and susceptibility of minors to negative influences
confirm that California should
be allowed to restrict minors’ access to offensively violent
material as it has done here.
In Ginsberg, this Court held that States may restrict the sale of
offensive sexual material
to children, notwithstanding that the First Amendment fully
protects such material as to adults.
The court below erred when it held that the Ginsberg analysis is
limited to sexual images.
Ginsberg does not turn on the difference between sexual images
and other forms of speech. Like
much of the Court’s jurisprudence before and after Ginsberg —
often having nothing to do with
sexual material — this case is premised upon society’s
traditional interest in protecting children
from harm and helping parents direct their children’s moral and
social development.
California’s statutes restricting the sale of offensively violent
video games to children
serve precisely these interests. Violent video games, like sexual
images, can be harmful to
minors and have little or no redeeming social value for them.
When sold to minors, offensively
violent material must be recognized as a “categor[y] of speech
that [has] been historically
unprotected, but [has] not yet been identified or discussed as
such in our case law.” — United
States v. Stevens (2010). The Court should adopt the Ginsberg
standard here so that the States
may support parents’ efforts to protect children from this
material as part of their long-

recognized duty to direct their ethical and moral development.
A. The First Amendment Allows the Government to Enact
Restrictions That Prevent Harm to
Children and Enable Parents to Guide Their Children’s
Upbringing.
The First Amendment provides: “Congress shall make no law
…. abridging the freedom of
speech.” Laws that restrict the content of speech are
presumptively invalid, and the government
has the burden of proving otherwise. “From 1791 to the present,
however, the First Amendment
has ‘permitted restrictions upon the content of speech in a few
limited areas,’” including
obscenity, defamation, fraud, incitement, and speech integral to
criminal conduct. — Stevens.
The prevention and punishment of speech that falls into these
traditional categories “has never
been thought to raise any constitutional problem.”
“Context,” moreover, “is all-important,” FCC [Federal
Communications Commission] v.
Pacifica Foundation (1978), and the Court also has allowed the
government to regulate the
content of offensive speech that could harm children, even
though the speech would have been
fully protected in other contexts.
Such regulations are constitutionally permissible, in part,
because this Court has
recognized that minors’ First Amendment rights are often less
extensive than those of adults. The
liberty of human expression guaranteed by the First Amendment
— the freedom to choose for
oneself what to publish, read, or view in order to promote a free
trade in ideas — presupposes the
capacity of the individual to make a reasoned choice. The

proper interpretation of the First
Amendment recognizes the fact that minors are not possessed of
mental faculties equivalent to
adults, and reflects society’s well-established understanding
that for certain narrowly defined
areas of expressive material, minors lack the capacity to make a
reasoned choice. The right of
parents to involve themselves in such decisions is entitled to the
support of the law.
This Court has recognized that children occupy a unique place
in civil society. This
principle has borne itself out in two ways in the Court’s
precedent: (1) a recognition that parents
must have substantial freedom to direct the upbringing of their
children; and (2) a recognition
that minors’ rights may be curtailed in ways that the rights of
adults may not. Consistent with
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these principles, this Court has recognized that the First
Amendment rights of minors are not
“co-extensive with those of adults.” — Erznoznik v. City of
Jacksonville (1975). Accordingly,
the government can bar the sale of sexual material to minors
even when, in other contexts, the
First Amendment would protect the material.
In Ginsberg, a store owner was convicted of violating a New
York statute prohibiting the

sale to minors of material the State legislature found to be
harmful to minors, although it was not
obscene as to adults. The statute at issue was directed at images
of simple “nudity,” as well as
sexual depictions — “girlie magazines,” as the Court referred to
them.
Although the New York law at issue in Ginsberg would not
have survived judicial
scrutiny had it applied to adults, this Court upheld the law
because it targeted purchases only by
minors. The Court recognized the State’s power to define
obscenity in a variable manner —
using one definition applicable to adults and a more broad
definition applicable only to minors.
Thus, the Ginsberg Court applied the following standard: “To
sustain State power to exclude
material defined as obscene by [the statute] requires only that
we be able to say that it was not
irrational for the legislature to find that exposure to material
condemned by the statute is harmful
to minors.”
The Court focused on the offensive, harmful nature of the
speech when consumed by
children, rather than on the sexual content of the speech.
Specifically, the Court cited two
interests that justify a relaxed application of the First
Amendment. First of all, constitutional
interpretation has consistently recognized that the parents’
claim to authority in their own
household to direct the rearing of their children is basic in the
structure of our society.
The second interest that justified a relaxed standard is that the
“State also has an
independent interest in the well-being of its youth.” While
supervision of children is best left to
parents, parental guidance “cannot always be provided,” and

society has “a transcendent interest
in protecting the welfare of children.” The Court cited Prince v.
Massachusetts (1944), which
upheld the enforcement of Massachusetts’s child labor law
against the guardian of a 9-year-old
girl for this fundamental, yet self-evident proposition. There,
the Court “recognized that the State
has an interest ‘to protect the welfare of children’ and to see
that they are ‘safeguarded from
abuses’ which might prevent their ‘growth into free and
independent well-developed men and
citizens.’” — Ginsberg.
Consequently, Ginsberg turns on two interests that focus on
children and parents rather
than on any inherent difference between sexual speech and other
forms of speech that may harm
children. This Court has continued to focus on these interests in
assessing the constitutionality of
regulations that seek to protect minors from the potentially
harmful effects of otherwise
protected speech.
In a case that involved offensive words, not sexual images, this
Court held that the
government could regulate speech that would be otherwise fully
protected, in part because of
potential harm to children. In Pacifica, the Court considered the
FCC’s authority to proscribe
radio broadcasts that it found “indecent but not obscene.” The
speech was a radio broadcast of
George Carlin’s 12-minute monologue “Filthy Words,” a
satirical discussion of swear words that
“you can’t say on the public ... airwaves.” Notably, while some
of the words had sexual
connotation, others did not, nor did the case involve sexual
images, as in Ginsberg.
In upholding the FCC’s authority to regulate the broadcasting

of such material, the Court
focused not only on the unique qualities of broadcast media, but
also on the potential harm to
minors in the listening audience. The Court found that the
language at issue — the seven dirty
words — “could have enlarged a child’s vocabulary in an
instant.” Citing Ginsberg, the Court
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noted “the government’s interest in the ‘well-being of its youth’
and in supporting ‘parents claim
to authority in its own household,’” which along with the “ease
with which children may obtain
access to broadcast material ... amply justify” a more flexible
application of the First
Amendment.
In focusing on the interests of parents and children, Ginsberg
and Pacifica are not novel.
This Court often considers society’s traditional interests in
supporting parents and protecting
children when determining the scope of a variety of
constitutional rights.
The Court has specifically invoked these interests in the
context of public schools.
Although students do not “shed their constitutional rights at the
schoolhouse gate,” Tinker v. Des
Moines Independent Community School District (1969), it is
well settled that “the constitutional

rights of students in public school are not automatically
coextensive with the rights of adults in
other settings.” — Bethel School Dist. No. 403 v. Fraser (1986).
Although this is due in part to
“the special characteristics of the school environment,”
Hazelwood School District v. Kuhlmeier
(1988), the treatment of students’ rights in the school setting
also reflects “the obvious concern
on the part of parents, and school authorities acting in loco
parentis [in place of parents], to
protect children.”
Accordingly, the Court has considered cases involving student
speech in public schools
in this context and has often shown flexibility toward public
school officials in regulating
offensive speech of various types. Like parents, “public
education must prepare pupils for
citizenship in the Republic. ... It must inculcate the habits and
manners of civility as values in
themselves conducive to happiness and as indispensable to the
practice of self-government in the
community and the Nation.”
Although the Court has upheld a student’s right to wear an
armband to protest the
Vietnam War, it has allowed school officials to sanction
students for their lewd comments made
to fellow students, to remove books from a school library that
officials deemed vulgar, and to
sanction a student for displaying a banner when school officials
reasonably concluded it
promoted drug use, even though the student himself described
the banner as mere “nonsense”
and members of the Court variously described it as “cryptic,”
“ambiguous,” “silly,” and
“ridiculous.” — Morse v. Frederick (2007). Notably, none of
these cases involved speech that

would have met Ginsberg’s variable obscenity standard.
Although school cases present their own unique circumstances,
the flexibility that the
Court allows public school officials is instructive here. If public
schools may permissibly restrict
students’ free speech rights, then the State of California should
be allowed no less authority
when they pass legislation designed to do nothing more than
reinforce parents’ right to directly
control the upbringing of children. To hold otherwise would
effectively grant public schools
(arms of the State) greater authority to directly restrict minors’
speech rights than a State itself
has when it acts to reinforce parental rights over their own
children.
Reviewing the law more broadly, society’s interest in
protecting children from harm from
a variety of sources, not just obscenity, and assisting parents in
this important task is well-
established in our Nation’s history and traditions.
It is not simply in the First Amendment arena that minors’
rights are restricted. Society
recognizes the utility and legitimacy of a differential between
the rights of minors and the rights
of adults because minors are not sui juris [legally competent].
They cannot vote and thus “might
be considered politically powerless to an extreme degree.” —
City of Cleburne v. Cleburne
Living Center (1985). And in California, as in many States and
the District of Columbia, minors
generally cannot marry without parental consent, serve on a
petit jury or grand jury, obtain a

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chauffer’s license or drive a school bus, purchase tobacco, play
bingo for money, or execute a
will. And, of course, States may restrict their access to sexually
explicit, harmful material.
Such laws, many of which could encroach upon fundamental
rights in other contexts,
present no constitutional problems because this Court “long has
recognized that the status of
minors under the law is unique in many respects” and “‘children
have a very special place in life
which law should reflect. Legal theories and their phrasing in
other cases readily lead to
fallacious reasoning if uncritically transferred to determination
of a State’s duty towards
children.’” — Belotti v. Baird (1979).
This Court has jealously guarded the “unique role in our
society of the family, the
institution by which we inculcate and pass down many of our
most cherished values, moral and
cultural.” — Belotti. To foster this relationship “requires that
constitutional principles be applied
with sensitivity and flexibility to the special needs of parents
and children. We have recognized
three reasons justifying the conclusion that the constitutional
rights of children cannot be equated
with those of adults: the peculiar vulnerability of children; their
inability to make critical
decisions in an informed, mature manner; and the importance of
the parental role in child
rearing.”

The decisions in Pierce v. Society of Sisters (1925) and
Wisconsin v. Yoder (1972)
demonstrate an understanding by this Court that the
Constitution guarantees parents full
authority to direct their children’s development. In Pierce, the
Court held unconstitutional
Oregon’s compulsory education law, which required every
parent of a child between the ages of
8 and 16 years to send their children to a public school. The
Court found that such a requirement
“unreasonably interferes with the liberty of parents and
guardians to direct the upbringing and
education of children under their control.” Recognizing the
separate, and sometimes conflicting,
roles of the State and the parent, the Court noted that “[t]he
child is not the mere creature of the
State; those who nurture him and direct his destiny have the
right, coupled with the high duty, to
recognize and prepare him for additional obligations.”
In Yoder, the Court rejected the State of Wisconsin’s argument
that exempting Amish
children from compulsory public education up to the age of 16
would fail to recognize the
substantive right of the child to a secondary education and
would curtail the power of the State as
parens patriae [the State’s parenting power] to extend the
benefit of secondary education to
children regardless of the wishes of their parents. Instead, the
Court recognized that it was the
parents’ rights, not those of their children, which would
determine Wisconsin’s power to
mandate compulsory public education.
It is upon these foundational principles that we, as a society,
recognize that parental
authority over minors is the bastion of ultimate liberty in
adulthood. “Properly understood, then,

the tradition of parental authority is not inconsistent with our
tradition of individual liberty;
rather, the former is one of the basic presuppositions of the
latter. Legal restrictions on minors,
especially those supportive of the parental role, may be
important to the child’s chances for the
full growth and maturity that make eventual participation in a
free society meaningful and
rewarding.” — Belotti.
In addition to reflecting the interests of parents in directing
the upbringing of their
children, this Court’s jurisprudence has specifically identified
the physiological reasons why
minors are not yet capable of exercising the full panoply of
constitutional rights. In Roper v.
Simmons (2005), the Court recognized three important
differences between adults and minors
under 18 which compel States to apply differing legal standards
that will accommodate such
differences: “First, as any parent knows and as the scientific
and sociological studies respondent
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and his amici cite tend to confirm, ‘[a] lack of maturity and an
underdeveloped sense of
responsibility are found in youth more often than in adults and
are more understandable among
the young. These qualities often result in impetuous and ill

considered actions and decisions.’”
Second, the Court found that “juveniles are more vulnerable or
susceptible to negative
influences and outside pressures, including peer pressure. ...
This is explained in part by the
prevailing circumstance that juveniles have less control, or less
experience with control, over
their own environment.”
And third, the Court noted that “the character of a juvenile is
not as well formed as that of
an adult. The personality traits of juveniles are more transitory,
less fixed.” Notably, the Court
based its holding on research produced by social science — the
same type of social science relied
upon by the California legislature — recognizing that the
susceptibility of minors to harmful
effects of external influences, well beyond that of adults,
justifies differentiations in treatment in
the eyes of the law.
Just recently, in Graham v. Florida (2010), this Court
reaffirmed the importance of these
distinguishing factors: “As compared to adults, juveniles have a
‘lack of maturity and an
underdeveloped sense of responsibility’; they ‘are more
vulnerable or susceptible to negative
influences and outside pressures, including peer pressure’; and
their characters are ‘not as well
formed.’”
These same concerns illustrate why allowing minors
unrestricted access to offensively
violent material is particularly antithetical to the goals of
society. If minors are “more vulnerable
or susceptible to negative influences,” that will be equally true
of the offensively violent video
games that would be restricted under the act. Similarly, because
the adolescent brain is still

developing and “the character of a juvenile is not as well
formed as that of an adult,” Roper, the
California legislature should have the flexibility to limit
children’s access to a narrow category of
offensively violent video games that depict and even reward
gruesome violence such as
decapitations, torture, and mutilation.
This Court’s continuing concerns with the unique status of
minors under the law, the
societal interest in protecting them from harmful material, and
the fundamental right of parents
to direct their moral and ethical growth are all addressed by the
Act. Applying the standard of
review set forth in Ginsberg to the facts of this case will allow
California to lend support of the
law to promote these critical concerns.
B. The Ginsberg Standard Strikes the Proper Balance Between
Minors’ Rights and the
States’ Interest in Helping Parents Direct the Upbringing of
Their Children.
Ginsberg should be applied to the act. It is an established, 40-
year-old standard that strikes an
appropriate balance between the relevant interests. Strict
scrutiny, on the other hand, would
nullify any meaningful evaluation of those interests. Moreover,
the type of violent material at
issue here is similar to other forms of unprotected speech, and
offensive violence may certainly
be a feature of sexual material that can be regulated under
Ginsberg.
Applying the Ginsberg standard to violent material aimed at
children, rather than
exclusively to sexual material, furthers the very same interests
repeatedly recognized by this

Court. The Ginsberg standard, which was built upon established
constitutional principles that
have since been set forth with particularity in Miller v.
California (1973), strikes a careful
balance between the rights of minors and the fundamental
interests of parents and the State. It
allows States to restrict minors’ access to patently offensive
material that appeals to their deviant
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interest, unless it has serious redeeming value for minors. The
constitutionality of such a
regulation should not turn on empirical evidence, but on
society’s recognition of the importance
of the parental role in assessing the appropriateness of such
material given the distinct
characteristics of the child or adolescent.
Application of strict scrutiny, on the other hand, would
improperly elevate the right of
minors to purchase material that may be more harmful than the
magazines at issue in Ginsberg,
while minimizing fundamental interests of parents and the State.
To apply strict scrutiny to the
act would impede the States’ ability to assist parents in
protecting minors in the face of new and
developing media. Such an unrealistically searching level of
judicial review is often described as
“strict in theory, but fatal in fact,” Fullilove v. Klutznick

(1980), and would place a nearly
insurmountable hurdle in the path of legitimate, well-reasoned
legislation that seeks to protect
minors.
In First Amendment jurisprudence, strict scrutiny often applies
to ensure that the rights of
adults to partake in a robust marketplace of ideas are not
restricted by the government absent
justifications of the highest order. However, the individual right
to consume speech is
inextricably intertwined with the expressive material’s
worthiness of constitutional protection in
any given context. For example, when traditionally obscene
material is at issue, the First
Amendment rights of individuals give way to the States’ right to
prevent the material’s public
dissemination.
Thus, in the seminal case Roth v. United States (1957), this
Court held that “implicit in
the history of the First Amendment is the rejection of obscenity
as utterly without redeeming
social importance.” Ginsberg and Pacifica, however, make clear
that, when children are the
audience, other interests are also relevant. Strict scrutiny
properly applies where there is both a
right to receive the material by the audience, and the material
itself is worthy of constitutional
protection considering the audience to which it is directed.
Neither of these elements is present
when California restricts the sale of offensively violent video
games to minors.
As this Court recognized in Ginsberg, the governmental
interest served by restricting
minors’ access to certain expressive material is not limited to
protecting them from physical or
psychological harm. It also assists in preventing the impairment

of minors’ “ethical and moral
development.” Surely, the First Amendment cannot be applied
in a manner that would require
empirical proof of how expressive material impacts such
nebulous concepts as one’s ethics or
morals.
Instead, a legislative body should be permitted to act
cautiously in the interests of society
if it rationally determines that offensively violent video games
depicting brutal and sadistic acts
committed by the game player are likely to harm the
development of a child. The Ginsberg
standard properly balances the rights of minors and adults with
the rights of parents and the
States, and provides the appropriate level of protection to which
the expressive material is
entitled, given its audience.
The Ginsberg standard also should apply here because
offensively violent material, when
marketed to minors, shares similar characteristics with other
forms of unprotected speech. The
rationale underlying the Court’s refusal to extend the First
Amendment’s protections to certain
categories of speech applies equally with regard to offensively
violent material sold to minors.
As a society, we have historically understood that obscenity,
which has varied in definition over
time, is outside the protection of the First Amendment. At the
time of the framing of the
Constitution, every State criminalized blasphemy or profanity
as well, and the vast majority

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provided for the prosecution of libel. Similarly, Federal law has
consistently criminalized the
transportation of obscene materials across State lines.
As is true of these other forms of unprotected speech,
offensively violent speech aimed
at minors can be harmful, and our Nation’s traditional interest
in protecting minors outweighs
any benefit derived from such speech. History amply supports
this conclusion. In addition to
regulating the distribution of sexual material, especially as to
minors, many States have regulated
violent material as well. These laws reflect a societal
understanding that violent material can be
just as harmful to the well-being of minors as sexually explicit
material.
Finally, when determining whether the Ginsberg standard
should apply to offensively
violent material as well as sexual material, it is important to
note that violence already plays a
major role in First Amendment jurisprudence. Otherwise
protected sexual material can qualify as
obscenity, even as to adults, based upon the violent nature of its
depiction. Images of extreme
sexual torture, for example, can be considered obscene by the
prevailing standards of any given
community. In many cases, but for the violent content, the
sexual nature of the material would
not be legally obscene.
Admittedly, these existing obscenity laws link violence with
sexual material.
Nevertheless, if violent content can strip otherwise protected

material of its constitutional
protection, then offensively violent content alone should be
considered unprotected expression,
at least with respect to its sale to minors. The harms averted and
societal interests promoted
through the regulation of sexual and violent material are merely
two sides of the same coin. It
would be ironic indeed if the First Amendment were interpreted
to permit States to assist parents
in protecting minors from sexual material — depictions of
images and acts that they may legally
engage in after the age of majority — yet prohibit them from
protecting minors from offensively
violent material — depictions of acts that they may never
legally engage in.
C. The Act Properly Reinforces Parental Authority Over
Minors, and Comports With Both
the Traditional and the Present Understanding of the First
Amendment Rights of Minors.
1. The act serves fundamental societal interests.
Applying the principles underlying Ginsberg and its progeny,
and recognizing the vital interests
of the State and the rights of parents to direct the upbringing of
their children, the act comports
with the requirements of the First Amendment. Through its
limited application, the act properly
allows the State to reinforce parental authority over minors to
protect them from offensive and
harmful material. Parents are entitled to such reinforcement
because the California legislature
rationally determined that offensively violent material is just as
harmful to minors, if not more
so, as sexual material.

By definition, the act covers only those video games where the
player can kill, maim,
dismember, or sexually assault an image of a human being in a
manner that a reasonable person,
considering the game as a whole, would find (1) appeals to a
deviant or morbid interest of
minors, (2) is patently offensive to prevailing standards in the
community as to what is suitable
for minors, and (3) causes the game, as a whole, to lack serious
literary, artistic, political, or
scientific value for minors. As with obscenity, fighting words,
and other forms of unprotected
speech, the violent video games covered by the act, by
definition, add nothing to the free
exchange of ideas for minors, do not represent a step to the
truth, and any benefit to be derived
from them by minors is clearly outweighed by the societal
interest in order and morality.
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Whatever First Amendment value these games may possess for
adults, they are simply not
worthy of constitutional protection when sold to minors.
The act also serves to eliminate the perceived societal approval
of minors playing
offensively violent video games — a distinct developmental
harm recognized by this Court. By
prohibiting minors from independently purchasing the covered

video games, the act serves to
remove any possible imprimatur of societal approval. The act
thus serves to leave the minor’s
identification process in the hands of the parents without any
contradictory message from the
State.
The act allows California to carry on this Court’s tradition of
supporting parental rights
over minors. Particularly with respect to material that can cause
a child or adolescent to be more
prone to aggressive, antisocial behavior, California has a strong
interest in allowing parents to
ensure that their children will not be exposed to violent video
games without their knowledge
and consent, allowing them to direct the upbringing of their
children in the manner they see fit.
Further, the act is limited to minors, who do not always have
the same First Amendment rights as
adults. As with pornographic speech, California may properly
limit minors’ access to the
offensive violence in certain video games so long as it is not
irrational for the legislature to
determine that the video games covered by the act are harmful
to minors. As is made clear from
the studies in the record, it was entirely rational for California
to make this determination.
2. Advancements in technology and social science reaffirm
society’s longstanding
concerns with minors’ exposure to violent material.
This Court has never suggested that a State may not regulate
minors’ unfettered access to
offensively violent material. And given the quantum leaps in
technology and social science since
this Court last considered a State’s attempt to regulate access to

violent material, this Court
should confirm that such regulations, if narrowly drawn and
limited to minors, comport with the
First Amendment.
The level of graphic detail and realism contained in many
modern violent video games is
without historical parallel. Such realism adds to the violent,
horrific nature of many video games
available to minors. Moreover, research has shown how media
violence generally, and video
game violence specifically, can lead to aggressive, antisocial
behavior and feelings. In a 2000
joint statement, the American Academy of Pediatrics, the
American Academy of Child &
Adolescent Psychiatry, the American Psychological
Association, the American Medical
Association, the American Academy of Family Physicians, and
the American Psychiatric
Association stated that 30 years of research demonstrates that
entertainment violence has
negative impacts on children. The group concluded that children
who are exposed to violence are
more likely to use violence to resolve conflicts. They are more
likely to be desensitized to
violence and are more likely to mistrust others. Similar findings
have been made with respect to
violent music lyrics and violent video games.
3. Respondents’ own system of self-regulation recognizes that
certain video games are
not appropriate for minors given the level of violent content.
The traditional understanding of the proper place of violence in
the spectrum of material that is
appropriate for minors continues today. And it is even
demonstrated by the Respondents’ own

rating system. The Entertainment Software Ratings Board
(ESRB) gives video games ratings
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from EC (Early Childhood) up to AO (Adults Only), which
represent age-based
recommendations to retailers. Violent content is a factor
considered by the ESRB in every single
rating.
For example, games will receive a rating of M (Mature) if they
“contain intense
violence, blood and gore, sexual content, and/or strong
language.” The ESRB even rates games
based solely upon violent content, absent any sexual
component: Games will receive a rating of
E 10 + (Everyone 10 and older) if they contain “minimal
cartoon, fantasy or mild violence and/or
infrequent use of mild language.”
Respondents’ own rating system thus acknowledges that, as a
society, we continue to
believe that there exists a level of violent content in expressive
material that is not appropriate
for consumption by minors absent parental guidance.
With regard to their distribution to minors, both sexually
explicit and violent material
exist at the periphery of the First Amendment. Neither
represents an essential part of any
exposition of ideas for minors absent parental guidance, nor

does their social value represent a
step to truth. Accordingly, like obscene material, offensively
violent material sold to minors
should not receive a level of First Amendment protection that
would trigger strict scrutiny.
California must be allowed to reinforce parents’ right to direct
the upbringing of their children by
protecting them from material that Respondents themselves
believe is inappropriate for minors.
Properly interpreted, the First Amendment poses no barrier to
California’s efforts to limit the
unfettered access of minors to offensively violent video games
through the act.
II. The First Amendment Does Not Demand Proof of a Direct
Causal Link Between
Exposure to Violent Video Games and Harm to Minors.
When the government defends a regulation on speech as a
means of preventing anticipated
harms, Turner Broadcasting System, Inc. v. FCC (1994)
properly requires reviewing courts to
uphold legislators’ predictive judgments of harm when they
have “drawn reasonable inferences
based on substantial evidence.” The court below imposed a far
more stringent standard of proof
that will affect future cases on a broad variety of subjects.
Petitioners ask this Court to reject the
heightened standard of proof imposed by the lower court.
Requiring legislative bodies to come
forward with proof of direct causation of harm to minors would
effectively eliminate the States’
ability to help parents protect the health and welfare of minors
when the protective measure
touches upon protected rights.
Never has this Court required a legislative body to come

forward with proof of a direct
causal nexus between offensive material and physical or
psychological harm to minors. Such an
evidentiary requirement would presumably entail
experimentation on minors in order to justify
legislation seeking to protect them from harm. In order to show
direct causation, researchers
would theoretically be required to isolate a minor from all other
forms of violence (be it media
violence, school violence, or family violence), while exposing
the minor only to violent video
games in order to determine whether such exposure directly
causes the negative physical and
psychological impacts observed by the existing literature. Such
a study would be as unethical as
it is impracticable. By effectively requiring it, the Ninth Circuit
placed California in a situation
where it could only justify a law prohibiting the sale of violent
video games to minors through
the use of a study that can never be performed.
Instead, any interpretation of the First Amendment must
recognize that responsible,
rigorous social science uses field experiments, cross-sectional
correlation studies, longitudinal
2010 (Vol. 13, No. 9)
Violent Video Games
studies, and meta analyses, combining the results of other
studies to form conclusions regarding

causation. Legislative bodies must be permitted to rely on this
established process in formulating
social policy. A proper application of the Turner standard
permits them to do so.
In Turner, this Court upheld Federal must-carry broadcast
provisions requiring cable
television systems to dedicate a portion of their channels to the
transmission of local broadcast
stations. In defending the regulation, the government relied
upon Congress’s legislative finding
that, absent mandatory carriage rules, “the continued viability
of local broadcast television would
be ‘seriously jeopardized.’” The Court accepted the
government’s justification for the regulation,
recognizing that “[s]ound policymaking often requires
legislators to forecast future events and to
anticipate the likely impact of these events based on deductions
and inferences for which
complete empirical support may be unavailable.”
Most recently, this Court acknowledged that the government
cannot be expected to obtain
the unobtainable when it acts to protect minors from the
harmful effects of indecent broadcast
media. In FCC v. Fox Television Stations (2009), this Court
held that “there are some
propositions for which scant empirical evidence can be
marshaled, and the harmful effect of
broadcast profanity on children is one of them. One cannot
demand a multiyear, controlled study,
in which some children are intentionally exposed to indecent
broadcasts (and insulated from all
other indecency), and others are shielded from all indecency.”
Never has this Court demanded proof of direct causation of
harm to minors in order to
justify a regulation on the speech they may consume absent
parental guidance. However, the

opinion of the court below does just that. In this case, the court
of appeals purported to apply the
standard set forth in Turner in reviewing the act, when it held
that the State failed to prove the
existence of a compelling governmental interest because “the
evidence presented by the State
does not support the legislature’s purported interest in
preventing psychological or neurological
harm. Nearly all of the research is based on correlation, not
evidence of causation. ... None of the
research establishes or suggests a causal link between minors
playing violent video games and
actual psychological or neurological harm.”
But by requiring proof of a direct causal link, the court below
effectively narrowed the
Turner standard. Indeed, the deference that the Turner Court
intended to provide to legislative
bodies was replaced in the decision below with an
insurmountable hurdle. Under existing social
science, empirical evidence of direct causation required by the
Ninth Circuit may well prove
unobtainable.
Although there have been even more studies since the
California legislature passed the
act, the evidence before it definitely established a correlation
between playing violent video
games and increased automatic aggressiveness, aggressive
thoughts and behavior, antisocial
behavior, and desensitization to violence in minors and adults.
This Court should reverse the opinion below, and reaffirm that
“[s]ound policymaking
often requires legislators to forecast future events and to
anticipate the likely impact of these
events based on deductions and inferences for which complete
empirical support may be
unavailable.” — Turner

III. The Act Is the Least Restrictive Means of Serving the
State’s Compelling Interests.
The Act represents the least restrictive means through which the
State can effectively achieve its
goals of helping parents direct the upbringing of children and
protecting them from harm caused
by playing offensively violent video games. The court of
appeals erred in holding otherwise.
2010 (Vol. 13, No. 9)
Violent Video Games
Specifically, the court of appeals held that even assuming the
State had demonstrated the
existence of a compelling interest, the mere “possibility that an
enhanced education campaign
about the ESRB rating system directed at retailers and parents”
could be a less restrictive means
to achieve the government’s interests, and therefore the Act
could not survive strict scrutiny. The
court also appeared to hold that because new gaming consoles
would contain parental controls,
the Act was not the least restrictive means of achieving the
legislature’s goals. Neither holding is
correct.
Respondents themselves acknowledged that the ESRB’s rating
system is entirely
voluntary, and not all video game publishers submit their games

to the ESRB for ratings. Thus,
for games receiving no ESRB rating, no amount of educational
campaigning will impact the sale
of such games to minors. And parental controls now available
on some gaming consoles would
apparently be useless. Moreover, any child with a computer or
gaming console connected to the
Internet can easily search the World Wide Web for instructions
on how to bypass the parental
control feature of any console.
As the Court recognized in Ashcroft v. American Civil
Liberties Union (2004), “The court
should ask whether the challenged regulation is the least
restrictive means among available,
effective alternatives.” Here, California demonstrated that the
act, through the imposition of civil
penalties, was the only effective means of ensuring that parents
have the ability to involve
themselves at the initial stage of the process. The California
legislature was not willing to simply
maintain the status quo, hoping that purported industry efforts
would eventually eliminate
children’s access to offensively violent video games. The proper
application of the First
Amendment in this context permits the State to intervene when
the industry fails.
Reply Brief
The following is excerpted from the Reply Brief of the
Petitioners as submitted to the U.S.
Supreme Court on October 8, 2010.
The statute attacked by Respondents shares nothing in common
with the statute at issue in this

case. Respondents and their amici paint an alarming picture of
government censorship of both
classic and contemporary art and literature, ignoring the level of
extreme violence depicted in the
narrow category of video games that is actually covered by the
act.
The act narrowly targets a distinct audience susceptible to
unique harms through use of
an established three-prong test that carefully ensures that
speech with serious literary, artistic,
political, or scientific value for minors will not be regulated.
Just as with laws governing the
regulation of obscenity and offensive sexual depictions, the
act’s reach is narrowly
circumscribed by its express terms.
Petitioners ask this Court to permit States to regulate minors’
ability to independently
purchase a narrow category of offensively violent material, just
as the Court has done for sexual
material. This material represents either depictions that are not
within the area of protected
speech as to minors or depictions that may be regulated in
respect to minors “because of their
constitutionally proscribable content” for minors, R.A.V. v.
City of St. Paul (1992), or both. The
important point is that the First Amendment should not be
understood either to guarantee
retailers a constitutional right to sell offensively violent video
games to unaccompanied minors,
or to guarantee minors the right to independently purchase this
limited class of video games.

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Journal of School Violence, 12:297–318, 2013
Copyright © Taylor & Francis Group, LLC
ISSN: 1538-8220 print/1538-8239 online
DOI: 10.1080/15388220.2013.803244
Do Children Who Bully Their Peers Also Play
Violent Video Games? A Canadian
National Study
CRYSTAL J. DITTRICK
Educational Studies in Counselling Psychology, University of
Calgary,
Calgary, Alberta, Canada
TANYA N. BERAN
Department of Community Health Sciences, University of
Calgary,
Calgary, Alberta, Canada

FAYE MISHNA
Factor Inwentash Faculty of Social Work, University of
Toronto,
Toronto, Ontario, Canada
ROSS HETHERINGTON
Hospital for Sick Children, University of Toronto, Toronto,
Ontario, Canada
SHAHEEN SHARIFF
Department of Integrated Studies in Education, McGill
University,
Montreal, Quebec, Canada
The study examined whether children who bully others are
likely
to prefer playing video games that are rated high in maturity
and
violence. A stratified random sample of Canadian children ages
10 to 17 years from the provinces of Canada was obtained.
Parents
(n = 397) and their children (n = 492) completed an online sur-
vey of children’s bullying behaviors and their three favorite
video
games. Ordinal logistic regression analyses showed that
parents’
and children’s reports of child preferences for mature and
violent
video games were significantly related to children’s
perpetration
of bullying and cyberbullying. Panel regression analyses
revealed
no significant difference between parent and child informants.

Received September 24, 2012; accepted April 22, 2013.
Address correspondence to Tanya N. Beran, Department of
Community Health Sciences,
Faculty of Medicine, University of Calgary, 2500 University
Drive NW, Calgary, AB T2N 1N4,
Canada. E-mail: [email protected]
297
298 C. J. Dittrick et al.
Children who play highly violent and mature video games were
likely to bully and cyberbully their peers, according to both
parent
and child reports.
KEYWORDS bullying, cyberbullying, video game maturity,
video
game violence, parent and child reports
Bullying is now recognized as a significant social problem
worldwide. Across
40 countries, Craig and colleagues (2009) found that 10.7% of
adolescents
(ages 11−15 years) reported bullying others, 12.6% report being
bullied, and
3.6% report both bullying others and being bullied. This
behavior can take
a variety of forms and involve varying methods, with the most
recent being
identified as cyberbullying involving bullying using a
communication device
such as a cell phone (Beran & Li, 2007; Mishna, Beran, Poole,
Gadalla, &

Daciuk, 2011; Wade & Beran, 2011). Prevalence rates vary with
approxi-
mately 11% to 17% of children cyberbullying others (Beran &
Li, 2005, 2007;
Li, 2006, 2007; Patchin & Hinduja, 2006). Given these high
rates, as well
as the evidence of negative consequences associated with
bullying (Beran,
Hughes, & Lupart, 2008, Beran, Mishna, Hetherington, &
Shaheen, 2011;
Hawker & Boulton, 2000), it is important to study risk factors
for bullying.
Playing video games, particularly those games involving
violence, is a well-
known correlate of aggression (Anderson, 2010a, 2010b). Less
is known,
however, about video gaming in relation to bullying. The
purpose of the
current study was to investigate the relationship between
children’s (ages
10−17 years) video game preferences and their perpetration of
bullying and
cyberbullying, utilizing both parent and child reports.
Bullying
Bullying is a unique form of interpersonal aggression. It
involves intention-
ality from the perpetrator to harm someone perceived as having
less power
(Olweus, 2010). Pepler, Craig, Jiang, and Connolly (2008)
described the
perpetration of bullying as a relationship problem whereby
children learn
to use power and aggression to cause distress for others and
control them.

Within Canada and the United States, approximately 22% of
boys and 16%
of girls report bullying others in one or more ways: physical
(e.g., hitting),
verbal (e.g., name calling), social (e.g., gossiping), racial (e.g.,
ethnic name
calling), sexual (e.g., comments and actions), and cyber (e.g.,
using a com-
munication device; Craig et al., 2009; Craig & Harel, 2004;
Pepler, Craig,
Ziegler, & Charach, 1993; Wang, Iannotti, & Nansel, 2009).
These perpetrating
behaviors harm targeted children’s cognitive, emotional, and
psychological
development (Gini & Pozzoli, 2009; Kaltiala-Heino, Rimpela,
Rantanen, &
Rimpela, 2000).
Bullying and Video Games 299
Cyberbullying has been defined inconsistently in the research
(Menesini & Nocentini, 2009; Patchin & Hinduja, 2006). On the
one hand,
some researchers suggest cyberbullying is a unique form of
bullying, along-
side other forms of face-to-face bullying such as physical,
verbal, and social
bullying (Wade & Beran, 2011; Dooley, Pyzalski, & Cross,
2009; Vaillancourt
et al., 2010; Wang et al., 2009). Other researchers suggest that
it is simply a
new medium through which traditional bullying can be inflicted
(Campbell,
2005; Menesini & Nocentini, 2009). Both perspectives suggest

that all these
types need to be measured. Cyberbullying involves the
perpetrator sending
embarrassing and/or hurtful messages in the form of email, text,
or pictures
through communications devices such as cell phones, laptops,
and desk
computers (Patchin & Hinduja, 2006; Ybarra & Mitchell, 2004).
Some defini-
tions suggest the aggressive behavior must be repetitive
(Patchin & Hinduja,
2006), whereas others suggest that it can involve a single act,
given that a sin-
gle act can be circulated widely or copied by others (Menesini
& Nocentini,
2009; Vandebosch & Van Cleemput, 2008). The power
differential between
the perpetrator and victimized individuals remains an important
criterion;
however, this power difference may involve technological
proficiency rather
than physical strength or popularity (Patchin & Hinduja, 2006;
Vandebosch &
Van Cleemput, 2008). Involvement in cyberbullying has
negative conse-
quences for the mental health of youth, over and above
traditional bullying
(Blais, 2008). In the present study, we adopted the definition of
cyberbullying
as at least one act of aggression directed through a
communications device
against someone with less power than the perpetrator.
Video Games
Video games are one of the most popular pastimes for children

in Western
society. They can be played on video gaming systems, as well
as most com-
munication devices, making them accessible virtually anywhere
an electronic
device can be operated (Anderson, Gentile, & Dill, 2012). A
recent nation-
ally representative study in the United States found that
children ages 8 to
18 years-of-age play video games approximately 1 hour and 15
minutes per
day with at least 60% of children playing on a given day
(Rideout, Foehr, &
Roberts, 2010). These authors report a variety of games played
by children,
some with high levels of violent and mature content (Rideout et
al., 2010).
The various video games available are rated for their “proper
age
category” or maturity level required to play and indicate the
explicit con-
tent, including violence, in the games (Gentile, Humphrey, &
Walsh, 2005).
The Entertainment Software Rating Board (ESRB) was
developed by the
Interactive Digital Software Association (IDSA) in an attempt
to classify
games into age-appropriate categories (similar to movie ratings;
ESRB, 2012).
Descriptions of maturity level indicate the presence of violence,
sex, explicit
language, and drug use in each game (Gentile et al., 2005). In
addition,

violence ratings identify the type of violence such as cartoon or
fantasy
violence in each game. Thompson and colleagues (Haninger,
Ryan, &
Thompson, 2004; Haninger & Thompson, 2004; Thompson,
Tepichin, &
Haninger, 2006) suggested that a majority of video games
contain violence.
Recent research has suggested that nearly half of youth (49%)
play at least
one video game rated as mature on a regular basis (Olson et al.,
2007).
In fact, some research suggests that the more mature the game
rating, the
more attractive the games are for youth, often entitled the
“forbidden fruits”
effect (Bijvank, Konjin, Bushman, & Roelofsma, 2008).
Video Games and Aggression
There exists a multitude of studies on the relationship between
video
games and aggressive cognitions, attitudes, and behaviors
(Gentile, Lynch,
Linder, & Walsh, 2004), with recent reviews (Bartlett, Anderson
& Swing,
2009; Ferguson, 2009) and meta-analyses (Anderson et al.,
2010a, 2010b;
Ferguson, 2007; Ferguson & Kilburn, 2009) providing
conflicting results
(Bushman et al., 2010; Ferguson & Kilburn, 2010; Huesmann,
2010). The
research community is “sharply divided” as to whether violent

video games
are harmful to children (Olson, 2004). The correlational,
experimental, and
longitudinal research suggests that aggression may be a
consequence of play-
ing violent video games (socialization hypothesis), an
expression of traits that
existed prior to playing violent video games (selection
hypothesis), or some
combination of the two (Anderson et al., 2007; Porter &
Starcevic, 2007).
Recently, Willoughby, Adachi, and Good (2012) investigated
both of these
hypotheses longitudinally with a sample of high school
students, finding
strong support only for the socialization hypothesis and not the
selection
hypothesis, suggesting that video game play may lead to
aggression over
time.
Violent video games may have short-term and long-term
influences
on aggression. In the short term, they may serve as a situation
variable
that increases a child’s aggressive thoughts, affect, and/or
arousal, lead-
ing to aggressive behavior. In the long-term, they may invoke
aggressive
beliefs, attitudes, schemas, behavioral scripts, and expectations,
as well as
desensitization to aggression, which may promote aggression
(Anderson &
Bushman, 2002; Carnagey & Anderson, 2004; Huesmann, 2007).
Willoughby
and colleagues (2012) indicated that this theory suggests: “Each

violent video
game episode may reinforce the notion that aggression is an
effective and
appropriate way to deal with conflict and anger” (p. 2).
It is possible that video games may lead to various types of
aggression,
including bullying (Olson, 2004). Indeed, several researchers
agree that vio-
lent video games are likely to have a stronger impact on
noncriminal or
less physically aggressive behaviors, such as bullying
(Anderson et al., 2010;
Ferguson & Kilburn, 2010). Although some recent studies have
examined
the relationship between video games and bullying,
cyberbullying has yet to
be included. Ferguson and colleagues (Ferguson, 2011;
Ferguson, Miguel, &
Hartly, 2009) have found significant but weak relationships
between level of
violence in videogames and bullying perpetration; however,
these samples
were not representative of the more general population and
utilized samples
of convenience (nonrandom). Whereas, Olson and colleagues
(Ferguson,
Olson, Kutner, & Warner, 2010; Olson et al., 2009) have not
found relation-
ships between video game maturity level and bullying
perpetration, even

with a more representative sample of American students in
grades seven
and eight (Ferguson et al., 2010). Clearly, research in this area
needs to
be informed by large representative samples to determine
whether game
violence and maturity are indeed related to bullying.
There is currently a limited understanding of how children’s
video
gaming behaviors may be related to their bullying behaviors.
Furthermore,
there are discrepant findings on the relationship between
aggression and
bullying perpetration, and there is no published research on
video games in
relation to cyberbullying. The current study examined whether
there was a
link between video gaming and cyberbullying perpetration. The
study design
utilized multiple informants (parents and children) from a large
Canadian
nationally representative sample. Thus, this study explored the
relationship
between the perpetration of bullying and the preference for
maturity and vio-
lence in video games among a nationally representative sample
of Canadian
children ages 10 to 17 years. Various types of perpetration,
parents’ and
children’s reports, and child gender and age differences were
also exam-
ined to determine whether children who prefer mature and
violent video
games bully others (controlling for child gender and age). We
hypothesized

that those children who played mature and violent video games
would be
involved in bullying perpetration.
METHOD
Sample
The sample consisted of 1,000 parents (n = 720 mothers, n =
280 fathers,
mean age = 43.0, SD = 9.9) and their children ages 10 to 17
years (n =
487 girls, n = 513 boys, mean age = 13.6, SD = 2.3) from all 10
provinces
of Canada randomly selected (using simple random sampling)
from a strati-
fied national household sample managed by a Canadian research
company.
This household sample had been obtained from government
census data
to ensure representation of the population based on several
demographic
characteristics such as geographic location, age, and family
size. They had
also agreed to be contacted for research purposes. Parents of
children within
the age group (10- to 17-year-olds) in the household sample
were randomly
selected and contacted by e-mail to request consent for
themselves and one
of their children to answer our online survey. The consent rate

was 96.3%.
The majority of the families lived in urban areas (72.8% urban,
27.2% rural),
and the majority of the children were born in Canada (89.9%).
English was
the most common language spoken at home (75%), followed by
French
(20%) and then other languages (5%). The demographic
characteristics of
the sample are representative of children living in Canada
(Statistics Canada,
2006). The current study reports on a subsample of participants
who reported
on children’s video game preferences; only 397 parents (n = 292
moth-
ers, n = 105 fathers, mean age = 41.4, SD = 9.4) and 432
children (n =
203 girls, n = 229 boys, mean age = 13.2, SD = 2.2) reported on
video
game preferences and thus, met the inclusion criteria.
Procedure
Parents were provided with a consent form that indicated they
were to com-
plete the survey about one of their children between the ages of
10 and 17;
they were to think of only that child when answering the
subsequent ques-
tions. If they had more than one child within that age group,
they were asked
to select their youngest child. Following consent, electronic
administration
began automatically. Parents completed the questionnaire,
which included
demographic questions and questions related to the specific

child’s involve-
ment in bullying and video games. Then they were instructed to
invite that
son or daughter (the person about whom they considered when
answer-
ing the questions) to complete the next set of questions
independently. The
parental consent rate was 96.2% (any responses from parents
whose child
did not participate were removed from the analyses). The
children were then
provided with the purpose and terms of the study and asked to
give assent.
All children who had received parental consent provided assent.
They were
then administered a questionnaire. Administration time of the
entire survey
was a mean of 21 minutes.
Measures
BULLYING
Parents and children were provided with the following
definition of bullying
(Pepler et al., 1993) adapted from Olweus’ questionnaire
(1989):
There are lots of ways to hurt someone. A person who bullies
wants to
hurt the other person. A person who bullies does it because they
can.
They may be older, stronger, bigger, or have other students on
their side.
There are different kinds of bullying:

● physical, for example, hitting, kicking, or spitting;
● verbal, for example, name-calling, mocking, or hurtful
teasing;
● social, for example, leaving someone out, gossiping, or
spreading
rumors;
● electronic, for example, on Facebook, e-mail, or text
messaging;
● racial, for example, saying hurtful things about someone
whose skin is
a different color;
● sexual, for example, kissing, grabbing, or saying something
sexual; and
● sexual preference, teasing someone for being gay whether
they are or
not.
Students were provided with the above definition, which
included the essen-
tial components (e.g., power differential) of bullying and no
additional
questions were asked assessing these criteria. After the
definition was pro-
vided, participants were asked one question about whether they
had bullied
others during the last month (referred to as general bullying
because it did
not address any particular type) and then seven follow-up

questions about
the type they perpetrated: cyber, verbal, social, physical, racial,
sexual com-
ments, or sexual bullying. Responses to all of these bullying
questions were
rated on a 5-point scale (no, once or twice, 2 or 3 times a
month, about once
a week, and several times a week), with higher scores reflecting
a higher
frequency of involvement. Due to a relatively small number of
responses
indicating once a week or several times a week, scores were
recoded on
a 3-point scale (1 = no, 2 = once or twice, and 3 = more than 2
times a
month; a combination of 2 or 3 times a month, about once a
week, and
several times a week). Coefficient alpha of the seven types of
perpetration
was .82 for parent reports and .86 for child reports, indicating
good interitem
reliability.
VIDEO GAMES
Participants responded to an open-ended question asking them
to name the
children’s three favorite video games. This question has been
reported as
a standard method for assessing video gaming behavior
(Anderson & Dill,
2000; Ferguson, 2011; Gentile et al., 2009). Video games were
coded for
maturity level and violence using coding schemes developed by
Huesmann
and colleagues and adapted from the ESRB (Gentile et al., 2005,

2009;
Huesmann, Moise, Podolski, & Eron, 2003). The maturity
categories used
from the ESRB include: early childhood (ages 3 years and
older), everyone
(ages 6 years and older), everyone 10+ (ages 10 years and
older), teen (ages
13 years and older), mature (ages 17 years and older), and
adults only (not
intended for children under the age of 18 years). Values ranged
from 1 to
6 with higher scores indicating higher maturity. A high
correlation has been
reported between student ratings of maturity with expert ratings
(r = .75, p <
.001; Gentile et al., 2009), demonstrating good concurrent
validity. Violence
was coded with the modified ESRB content descriptors (i.e., 1 =
no men-
tion of violence, 2 = cartoon violence or mild animated
violence, 3 = mild
violence, fantasy or animated violence, or 4 = violence). Higher
ratings indi-
cated more violence. Content validity is demonstrated by basing
the coding
on the ESRB ratings, ratings of which are assigned through a
consensus of
three experts with familiarity of video games (ESRB, 2012).
The majority of video games were included in the ratings given
by the

ESRB (approximately 80% of all reported games). When codes
were unavail-
able on the ESRB website or game itself, the researchers viewed
or played
the games. Researchers independently reviewed the ESRB
website, which
contained information about what classified a game into a
maturity category
and about the content descriptors. The reviewers then viewed or
played the
game and examined the specific content to determine
classification (e.g.,
explicit language, sex, drugs, violence). Names of video games
given by
parents and children that were vague (e.g., “action series”), or
described a
device or website (e.g., “Nintendo Wii” or “anything on
ourworld.com”) were
not coded. Of the 583 different responses provided by parents
and children,
59 could not be coded.
The mean score of the three video games was used as the
maturity and
violence scores. Two raters coded all video games. For parent
ratings, the
interrater reliability (intraclass correlation coefficients) were
.95 for maturity
and .91 for violence. For children’s ratings, the interrater
reliability (intraclass
correlation coefficients) was .94 for maturity and .90 for
violence, indicating
good interrater reliability.
A total of 467 parents and 493 children did not answer the
question

about preferred video games. Perhaps they did not know the
names of video
games, the child may not have played video games, or other
unknown rea-
sons. In total, 397 parents and 432 children reported video
games that could
be coded, which formed the sample size in the analyses of video
game
maturity and violence. There were no significant differences in
demographic
characteristics or frequency of bullying between the samples
that did, and
did not, answer the question about video game preferences.
Statistical Analyses
Descriptive statistics were computed using the entire sample,
and for boys
and girls separately. Given the ordinal level of measurement of
bully-
ing, Spearman Rank correlations were computed to compare the
similarity
between parent and child reports of bullying, video game
maturity and vio-
lence ratings. Differences in parent and child reports of
preferences for video
game maturity and violence were compared between boys and
girls using
Multivariate Analysis of Variance (MANOVA). Also, gender
differences in the
bullying responses, as measured by the three-point response
scales, were
analyzed with Mann-Whitney tests. Spearman Rank correlations
were then
calculated to determine if children’s age, bullying, and video
game maturity

and violence were related. Ordinal logistic regression analyses
were used
to determine the relative importance of video game maturity and
violence
in relation to the various types of bullying perpetrated. Child
gender and
age, and general bullying perpetration were included in the
regression along
with their interaction effects. Finally, panel regression analyses
were used
to investigate informant effects, specifically differences
between parent and
child reports.
RESULTS
Descriptive Statistics
The maturity and violence scores for the video games and the
frequency of
all types of bullying for the overall sample, as well as boys and
girls sep-
arately, are shown in Table 1. The majority of games were rated
at a level
of everyone 10+ and mild violence/realistic violence. Also, the
frequency
of each type of reported perpetration was low. The correlations
between
parent and child reported video game maturity and violence and
all types
of bullying perpetration are reported in Table 2. The

concordance was high
for video game maturity (r = .83, p < .01) and violence (r = .83,
p < .01).
Thus, parents and children generally agree on the types of video
games
children prefer. The level of correspondence for bullying
perpetration was
moderate, depending upon the form of bullying. Thus, in
general, parents
and children report relatively similar levels of child
involvement in bully-
ing perpetration. Table 2 shows the correlations of the types of
bullying
perpetration with the maturity and violent content of video
games. The corre-
lations with the highest magnitude and largest number of
significance values
were for cyberbullying. This type and general bullying (as an
estimate of
various forms of perpetration) were used in subsequent
analyses.
Table 3 presents correlations separated by gender. MANOVA
analyses
showed significant gender differences for both parent and child
reports of
video game preferences. Parents reported higher levels of video
game matu-
rity and violence for their sons (M = 3.25, SD = 0.84, M = 2.20,
SD = 1.20,
respectively) than for their daughters (M = 2.64, SD = 0.75, M
= 1.22, SD =
1.22, respectively), Wilks’ lambda = .86, F (2, 394) = 33.29 p <
.001, partial
eta2 = .15. Similar results were found for children’s reports,
with boys pre-

ferring games with higher ratings of maturity and violence (M =
3.41, SD =
0.82, M = 2.30, SD = 1.22, respectively), than did girls (M =
2.67, SD = 0.77,
M = 1.15, SD = 1.18, respectively), Wilks’ lambda = .80, F (2,
429) = 54.12,
p < .001, partial eta2 = .20. Mann-Whitney tests showed
significant gen-
der differences for parent reports of general bullying (Mann-
Whitney U =
119034.00, p < .05), verbal bullying (Mann-Whitney U =
118381.00, p <
.05), and physical bullying (Mann-Whitney U = 119694.00, p <
.05) with
parents reporting higher levels of these types of bullying for
boys than for
girls. Gender differences were also found for child reports of
general bullying
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T
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